Linda S

. A d ams Secretary for
Enviro n m enta l Protection

The ene rgy challenge facing California is real . Every Californian n eeds to take imm ediate action to r educe energy co nsum ption.
For a list of sim p l e ways you can reduce de m and a nd cut your ene r g

y costs, see our website: http:// www.arb.ca.g ov 

# Air Resources Board

Mar y D. Nichols, Chairman

9480 Telstar Avenue, Suite 4 El Monte, California 91731 www.arb.ca.g ov A r nold Sc h w a r ze ne gge r Governor

February 24, 2009

Manufacturers Advisory Correspondence MAC #2009-01

To: ALL VEHICLE MANUF ACTURERS OF PASSENGER CARS,
LIGHT DUTY TRUCK S , AND MEDIUM-DUT Y PAS SENGER
VEHICL E S

Subject: Implementation of the Ne w Envir onmental Performance Label.

This letter transmits the enclosed Manuf acturers Advisory Correspondence (MAC) which outlines the process for implementing the new Environmental Performance (EP) label. The MAC discusses the EP label appr oval process for vehicles produc ed after January 1, 2009, and for vehicles produced prior to that date for whic h the manufacturer is voluntarily applying the EP label. In addition, the MAC discusses the approval process for receiving air conditioning (AC) emission reduction credits based on AC-direct and AC-indirect syst em improvements. And fi nally, the MAC outlines the global war m ing scoring procedure for Mediu m-Duty Passenger Vehicles certified under
California’s Cleaner F ederal Vehicle rule subj ect only to FTP testing from which only the measured city CO 2 values are reported.

If you have any questions regarding EP label fo rmat, please contact Mr. Craig Duehring,
Air Resour ces Engineer, ZEV Infrastructure Section, at (916) 323-2361 or by email at cduehrin@ a rb.ca.gov. For approval of credits for improved air conditioning sy stems, please cont act Mr. Tao Huai, Manager, Clima t e Change Mitigation a nd Emissio n Research Section, at ( 916) 324-2981 or by email at thuai@arb.c a.gov . For EP label score matters, please contact Ms. Rhonda Runyon, Air Pollution Specialist, On-Road Certification / Audit Section, at (626) 575-6653 or by email at rrunyon@arb.ca.gov

.

Sincerely,

/s/

Annette Hebert, Chief Mobile Source Operati ons Divis ion

Attachment

. California Environmental Protection Agency

Printed on Recycled Paper1 State of California
AIR RESOURCES BOARD

MANUFACTURERS ADVISORY CO RRESPONDENCE (MAC) 2009-01

SUBJECT: Implementation of the new Environmental Performance Label.

APPLICABILITY: All 2009 and subsequent model year passenger cars, light-duty trucks and medium-duty passenger vehicles produced on or after January 1, 2009, including t hose produced by small and
intermediate volume manufacturers.

The global warming scores (GWS) discussed in this MAC are determined pursuant to secti on 3(a)(2) of the California
Environmental Performance Label Specifications. Upon California receiving the federal waiver, t he GWS will be determined based on the requirements in 13 CCR 1961.1; additional guidance will be
issued as needed.

REFERENCES: Title 13, California Code of Regulations (CCR), Section 1965 and
“California Environmental Perfo rmance Label Specifications For 2009 And Subsequent Model Year Passenger Cars, Light-Duty Trucks, And Medium-Duty Passenger Vehicles” Adopted: May 2,
2008

Mailout MSO# 2007-03 “New Requirement to Report Carbon Dioxide Emissions from 2008 and Subsequent Model Year California Certified Vehicles and Engines”

BACKGROUND: Currently, all ve hicle manufacturers are prohibited from selling a passenger car or light duty vehi cle lacking a Smog Index label affixed for display at the point of sale. For vehicles produced on or after January 1, 2009, the manufactu rers are required to replace the Smog Index label with the new Environmental Performance (EP) label which includes both a Smog and Global Warming score. The new regulation allows for early implementation to
accommodate a smooth transition for replacing the Smog Index
label with the new EP labe l. This transition period ends on January 1, 2009 when only the new EP label will be displayed on each new vehicle. The regulation requires manufacturers to submit
labels to the ARB for review and approval prior to display of the new EP label. Since the majority of 2009 model year test groups are already certified, this MAC describes the approval process for 2009 model year test groups alre ady certified and the approval2 process for pending 2009 and subsequent model year applications.
Both scenarios are discussed below.

In addition, this MAC will discu ss the application and approval process for receiving air conditioning (AC) emission reduction
credits based on AC-direct and AC-i ndirect system improvements. Finally, this MAC outlines the global warming scoring procedure for Medium-Duty Passenger Vehicles certified under California’s Cleaner Federal Vehicle rule subj ect only to FTP testing, from which only the measured city CO 2 values are reported.

PROCESS: Approval of New Environmental Performance Label

A request for approval must cont ain the following two parts:

1. A sample EP label to evaluate the format in accordance with the regulations. And,

2. The data necessary to determine the Smog and Global Warming

scores.

A request for approval of the EP label format and the request to approve smog and global warming scores may be made under separate cover.

Requests for label format approval shall be submitted to:

Craig Duehring
Mobile Source Control Division 1001 I Street, P.O. Box 2815 Sacramento, CA 95812 Email: cduerhin@arb.ca.gov

Requests for smog and global warming score approval shall be
submitted to the On-Road Certification / Audit Section via the ARB’s Document Management Syst em (DMS). Manufacturers shall submit their request to the following folder within their DMS directory:

\\ARB MFR code – Manufacturer Name\PC-LDT\2009\CBI
APPLICATION\CORRESPONDENCE\MISCELLANEOUS

Manufacturers shall give their request the following file name:

CBI_9MFR_CORRESP_RFA*LAB_ where MFR is the U.S. EPA
manufacturers code.3 For 2009 model year test groups whic h are certified as of the date of this MAC, manufacturers shall submit one request for approval of their sample label and smog and global warming scores for all
certified 2009 model vehicles.

For pending 2009 model year applications and 2010 and subsequent model year applications , manufacturers shall submit sample labels for format approval and the data necessary to determine the smog and global warming scores for the vehicle models within their test group applic ation. Manufacturers shall submit the data necessary for score approval in the format
attachment to this MAC.

For 2009 model year vehicles manufactured prior to January 1, 2009, manufacturers ma y affix an approved EP label to vehicles in any of the following m anners: (i) the EP label in lieu of the Smog Index label; (ii) the EP label overlaying the Smog Index label; or (iii) the EP label in the pr oximity of the Smog Index label. All 2009 model year vehicles manufactured on or after January 1, 2009 must displa y only the new EP label.

The information necessary for approval of both the label format and
the label scores are described below.

Label Format Approval

Prior to displaying the new EP label on any vehicle, the manufacturer must submit a sample label to the person identified above for format review and approval. Only one sample label per manufacturer is required for format and size approval. However, if
a manufacturer uses both the st andard 4 x 6 inch label and the reduced 21⁄2 x 41⁄2 inch label, ARB wil l require samples of both label formats for approval. Staff will be lo oking for label color, size, font, style and overall specification compliance.

If the new EP label will be placed on label feedstock that contains other vehicle information, the samp le label must include the other vehicle information to be displa yed. If the manufacturer will be placing the new EP label within t he vehicle’s Monroney Sticker, staff will require a sample of th e entire Monroney sticker with the new EP label displayed. Finally, if a sample label is not immediately available due to feeds tock ordering lead time, staff will accept a .pdf file of the proposed label for review and temporary approval. However, once the feedstock is available with the new label format, the manufactu rer must submit a sa mple label to staff for final approval.4 Annual approval of label format is not required. However, ARB may require submission of sample labels periodically for compliance purposes. Staff will contact the manufacturer if additional sample labels are required.

Smog and Global Warming Score Approval

In order to receive approval of the smog and global warming scores the following information shall be s ubmitted. This information shall be submitted in the attached format by test group.

For Each Test Group:

• Models within the test group

• Emissions standard category

• The smog score

• CO 2 city and CO 2 highway values as reported in accordance with the August 29, 2007, ARB Mailout, MSO #2007-03

• Fuel adjustment factor

• Approved AC-direct and AC-indirect credit values

• CO 2 -equivalent combined value

• The global warming score

As mentioned above for 2009 model year test groups already certified, this information may be submitted for all test groups in a single request. For pending 2009 applications and 2010 model year applications, this information shall be included in each manufacturer’s test group specific app lication for certification. As mentioned above, submit requests via the ARB’s DMS. Please
submit the data in the excel format prescribed in the attachment to
this MAC.

A/C CREDITS: Emission Reduction Credits for Improved Air Conditioning (A/C) Systems

In accordance with section 3.(a)(2) of the “Californi a Environmental Performance Label Specifications For 2009 And Subsequent Model Year Passenger Cars, Light-Duty Trucks, And Medium-Duty Passenger Vehicles.” adopted May 2, 2008, vehicle manufacturers may submit applications for ARB approval to determine A/C-direct
and A/C-indirect emission reduc tion credits for A/C systems designed to reduce the amount of greenhouse gas emissions from A/C operation and leakage. Applic ations for emission reduction credits for improved A/C systems must be submitted separately from other approval requests and must be applicable to all vehicles
identified in each test group. Applications for A/C credits must clearly indicate that the A/C system emissions data submitted5 applies to all vehicles within the s pecified test group. If the A/C system emissions data does not apply to all vehicles within the test group, then no A/C credits will be earned for that test group.

In general, the regulatory equation used to calculate the global warming score of the vehicle a ssigns default values for the increased greenhouse gases emitted when using a typical air
conditioner with HFC-134a as the refrigerant. These default values, six grams carbon dioxide equivalents (CO 2 e)/mile for A/Cdirect and 17 grams CO 2 e/mile for A/C-indirect are inherently conservative since they represent the nominal level of emissions expected for a range of vehicles and systems. They are based on prior research and emissions modeling.

Applications to receive A/C-di rect and A/C-indirect emission reduction credits must prov ide an engineering analysis with laboratory results clearly s howing the technical and design advances that will yield reductions to these default values. The application must also contain descriptions of component-by-component modifications made to achieve increased refrigerant containment and system effi ciencies. All applications for
A/C emission reduction credits must provide actual certification test data to support the results submit ted and must clearly show all improvements made to achieve t hese results. In addition, the Executive Officer retains the right to ask for additional information as part of this application process.

The regulatory language provides the minimum application submission requirements to suppor t claims for A/C improvements. These submission requirements ar e repeated and further clarified
below for convenience.

Requests shall be submitted to:

Tao Huai, Manager Climate Change Mitigation and Emissions Research Section
Research Division 1001 I Street, P.O. Box 2815 Sacramento, CA 95812 (916) 324-2981 Email: thuai@arb.ca.gov

Craig Duehring
Mobile Source Control Division 1001 I Street, P.O. Box 2815 Sacramento, CA 95812 (916) 323-2361 Email: cduehrin@arb.ca.gov6 A/C DIRECT: A/C-Direct Emission Reduction Credits

For A/C-direct emission improvem ents in systems using HFC-134a as the refrigerant, the manufactu rer must demonstrate and submit for approval the following:

1. The manufacturer must demons trate via engineering evaluation that the A/C system minimizes overall refrigerant leakage by:

a. Minimizing the number of or improving fittings and joints. b. Limiting the use of single O-rings for pipe and hose
connections. c. Using lowest permeability hose for containment of the refrigerant. d. Minimizing leakage from co mpressor shaft seal and housing
seals.

Based on the above regulatory l anguage, staff is requesting the following information:

• Specify (types, numbers, leng ths, hose permeability and the permeability test proc edures employed, et c) the A/C system components that contribute to refr igerant leakage in the system in question. Provide sufficient specifications for the system in question to enable replication of the s ystem refrigerant emissions calculation using SAE International Standard J2727 . Attach the calculation spreadsheet base d on SAE J27 27 spreadsheet template.

• Provide illustrations or pictures of t he placement of components in the system in question.

• Provide description of design changes and ex plain how the number of fittings and joints ha s been minimized relative to a previous design/system.

• Justification of the use of single O-rings to qualify as a “low-leak” system, as applicable.

• Justification of the use of hose if lowest permeab ility hose (ultralow permeability barrier or veneer hose) is not used to qualify as a “low leak” system, as applicable.

• Explain how leakage fr om the compressor s haft seal and housing
seals has been minimized.7 If other improvements not reflecte d in SAE J2727 Standard are made to the system in question, the ma nufacturer is encouraged to provide
other relevant information to AR B as part of the application.

ARB is continually exploring how demonstration of leakage
determination via SAE J2727 can be enhanced. Results from miniSHED leak testing, results quant ifying production line mis-assembly rates, and any related information manufacturers wish to include in the application package would be very useful.

2. Annual leakage refrigerant em issions as tested and measured in accordance with SAE International standard J2727 indicating a measured annual refrigerant leak age of less than 55 grams. Although the regulation specifie s the July 2007 revision of SAE J2727, staff will accept data using the latest revision available. Each application must provide the leakage rate used to
calculate A/C-direct emission credits as determined using the
SAE J2727 calculation. In addition, each application must provide sufficient information for staff to replic ate the SAE J2727 calculation for the system in question.

If the A/C system is determined to be a “low-leak” system in accordance with paragraphs 1 and 2 above and if approved by ARB, the A/C-direct emissi on reduction credit will then be calculated using the following equation:

A/C-direct emission reduction cr edit = 6 – (SAE J2727 measured annual refrigerant leakage in grams) x 1,300 / 12,000

All applications requesting A/C-dire ct emission reduction credits must demonstrate they comply with the requirements and improvements identified in paragraphs 1 and 2 above.

For A/C systems using a refrigerant with a global warming potential of less than or equal to 150 times that of CO 2 , the global warming potential from refrigerant leakag e is considerably less than other annual greenhouse gas emissions and the manufacturer will get the
maximum A/C-direct emission re duction credit of six grams
CO 2 e/mile.

A/C INDIRECT: A/C-Indirect Emission Reduction Credit

A/C-indirect emission reductions c an be achieved if the A/C system is designed to be an “improved” system. To qualify as an “improved” system that uses CO 2 , HFC-134a, HFC- 152a, or other halocarbon refrigerant, the follo wing requirements apply and the
Executive Officer will review submi tted demonstrations for approval:8 1. The manufacturer must demons trate using test data in an engineering evaluation that the A/C system achieves lower A/Cindirect emissions than t he default value of 17 grams CO 2 e/mile.

The engineering evaluation in the application package should
include CO 2 vehicle test emissions data for operation without A/C (FTP) and with A/C (SFTP: SC03 test cycle conducted under test conditions described in 40 CFR 86.158 and related sections) as a means for determining indirect A/C emissions. The manufacturer
must submit CO 2 emissions results from these tests for the test group which the application for A/C cr edits applies. The eligibility of
A/C-indirect credit is determined from the FTP and SC03 CO 2 measured emission rates as follows:

The system qualifies if: [(SC03 CO2 ― 112) / (0.954 × FTP CO2 ) × 17] < 17.0 g/mi

The system does not qualify if: [(SC03 CO2 ― 112) / (0.954 × FTP CO2 ) × 17] ≥ 17.0 g/mi

The default value of 17 g/mi repr esents the difference between FTP with A/C operation and FTP without A/C operation, and is adjusted for the average fraction of time a vehicle’s A/C system is on in California. Existing certification test procedures do not include an FTP test cycle with A/C operation, but they do incl ude an SC03 test cycle with A/C operation under specifi ed conditions of temperature, humidity, and solar load. In order to avoid the need for additional testing, ARB will rely on data from ex isting certification test results to demonstrate A/C-indirect impacts.

For dedicated alternative-fueled vehicles (AFVs), which are not subject to SFTP testing, two opti ons are available with prior ARB approval. Manufacturers may test the official certification test
vehicle under the SC03 test procedure to determine the SC03
CO 2 -equivalent value. Or, manufacturers may provide an engineering evaluation co mparing the A/C system on the AFV to an identical or similar A/C system on an identical or similar gasoline or diesel vehicle and determining the CO 2 -equivalent emission
reduction due to A/C s ystem improvements.

A/C-indirect impacts are shown in Table 1. CO 2 emissions are higher during the SC03 than during the FTP, partly due to the A/C and partly due to cycle effects. The ov erall relationship is shown in Figure 1. This regression line is used to represent default values for the purpose of demonstrating impr ovements. A vehicle having a
reduced contribution of A/C to CO 2 emissions will fall below this line, and will be considered to have demonstrated improved A/C system performance.9 Table 1: Emissions Measured unde r FTP and SC03 Test Procedures

Vehicle
ID Vehicle
Class FTP w i th no
A/C SC03 w i th
A/C

1 Small Car 2 6 9

. 2 3 6 9

. 2

2 Midsize C a r 3 4 2

. 4 4 5 2

. 7

3 Midsize C a r 4 4 0

. 2 5 2 9

. 5

4 Large Car 4 5 4

. 3 5 4 8

. 7

5 Small Car 3 3 5

. 8 4 4 1

. 2

6 Midsize C a r 3 8 8

. 8 4 8 8

. 8

7 Large Van 9 4 2

. 6 1 0 2 1

. 9

8 Minivan 4 4 0

. 4 5 5 1

. 4

9 Small SUV 5 2 1

. 5 5 9 2

. 0

10 Minivan 4 6 8

. 6 5 1 9

. 6

11 Minivan 4 8 8

. 3 5 9 9

. 9

12 Large SUV 6 9 0

. 3 7 8 9

. 7

13 Van 6 9 6

. 0 7 5 8

. 1

14 Large Truck 5 4 3

. 6 6 1 5

. 5
15 Midsize C a r 4 2 7

. 7 5 0 8

. 5

y = 0

. 9 54x + 112

R 2 = 0

. 989

300 400 500 600 700 800 900 1 000 1 100

20 0 3 00 4 0 0 50 0 6 00 7 0 0 8 0 0 90 0 1 00 0

FTP CO 2 ( g /mi )SC03 CO2(g/mi)

Figure 1: Correlation betw een Emi ssions Measured under FTP and SC0310 2. The system must manage outside and re-circulated air balance to achieve comfort, demisting, and safety requirements, based on factors such as temperature, humidity, pressure, and level of fresh air in the passenger compar tment in order to minimize

compressor usage. 3. The system must be optimized fo r energy efficiency by utilizing state-of-the-art high efficiency evaporators, expa nsion devices, condensers, and other components. 4. The system must have external controls that adjust the evaporative temperature to minimi ze the necessity of reheating cold air to satisfy occupant comfort.

Each application must provide in formation about the configurations of the A/C system, includi ng, but not limited to , the types, sizes and features of each major componen t. Explain how the system has been designed so that it meets the above criteria 2 through 4.

An internally controlled A/C system could also qualify as an “improved” system as long as t he manufacturer demonstrates that the system achieves the same goal as minimizing the necessity for reheating cold air to satisfy occupant comfort. A detailed technical description of the system and syst em components proposed for qualification is required.

Staff will review the application on a case-by-case basis to determine if the system meets the criteria. Manufacturers are encouraged to provide additional technical assessment and other relevant information beyond the minimum specified in this guidance if the applicants believes it will fa cilitate staff’s determination.

If the A/C system is determined to be an “improved” system in accordance with paragraphs 1 through 4 above and if approved by the Executive Officer, the A/C-indi rect emission reduction credit will be calculated using the following equation:

A/C-indirect emission reducti on credit = 17 – (Compressor Displacement in cubic centimeters) x 5 / 100

Staff will review each application on a case-by-case basis and may generate an application template for future use in requesting AC system improvement assessment.

Global Warming Scores for Medium-Duty Passenger Vehicles (MDPVs)

Currently, MDPVs are certified to California medium-duty vehicle (MDV) standards or, under Califor nia’s Cleaner Federal Vehicle rule, to a federal Tier 2 standard that is deemed more stringent than11 California’s based on a comparison of the sums of the respective
NMOG and NOx useful life standa rds. Independent of the EP labeling regulations, MDPV certif ied to California MDV standards are tested under both the FTP and Highway Fuel Economy test procedures; their measur ed city and highway CO 2 values are used for determining the CO 2 -equivalent combined values discussed
above.

MDPV certified under California’s Cleaner Federal Vehicle rule are subject only to FTP testing from which only the measured city CO 2 values are to be reported. Bas ed on 2007 model year certification data, MDPV certified to Calif ornia’s MDV standards have a
CO 2 -equivalent combined range fr om 565 – 729 grams per mile
CO 2 -equivalent. Per the EP labeling regulations, any CO 2 combined value greater t han 520 grams per mile CO 2 -equivalent will receive a global warming score of “1”, the lowest possible. Therefore, ARB concludes that all MDPVs will get a global warming
score of “1.”

ARB encourages manufacturers of MDPV, especially those MDPV to be certified under California’s Cleaner Federal Vehicle rule, to
submit both CO 2 city and CO 2 highway values when applying for
the new EP label. Manufacture rs may use the Highway Fuel Economy test procedure applicable to California’s MDV – again, independent of the EP labeling regulations – to test the official
MDPV emission data vehicle and submit the measured CO 2 highway value for determining the CO 2 -equivalent combined values
of the MDPV families certified und er California’s Cleaner Federal
Vehicle rule. If the manufacture r of a MDPV does not submit CO 2 highway values with t heir application, the CO 2 city value alone shall
be used to calculate the CO 2 -equivalent combined value for purposes of determining the global warming score.